p.1 

OAR Box 1793 

Prepped by Keeia Richards 

Document Number: 

17) ll-F-59 

Docket Number: 

A-90-37 

Printed 11/3/2008 11:31:54 AM Sheet 17 of 45 
P.2 

10/24/95 16:39 ©30 3 969 2822 WASO DENVER Ig]001/017 

A-90-37 

3JT- F-$V 

NATIONAL PARK SERVICE 

AIR RESOURCES DIVISION 

P.O. BOX2S287, Denver, CO 80225-0287 

^ 

FACSIMILE COVER SHEET 

To: De/Vl/'S (f*>*plf/^ 

FMJOL g £ 

Telephone: (303) 

Fax: (303) 969-2822 

Subject: Of*/!,'*> Uft,\ n**it*J* ^kt fo„ ft^kf o*a to^^iz ryUy 

fi^t ire. fif^LL '(4w*> U tfuontk AJL^ £./«;*>. Nf fas 

Number of Pages: 

(Including this cover sheet) 

Office Location: J2795 W. Alamf.ua Paway, Room 215, Lakewood, CO 80228 
, P.3 

10/24/95 16:39 ©303 969 2822 . WASO DENVER ®002/017 

February 13, 1992 

N3615 (SER-ODN) 

Mr. CH. Fancy, P.E., Deputy Chief 

Bureau of Air Quality Management 

Florida Department of Environmental Regulation 

Twin Towers Office Building 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Mr. Fancy: 

We have reviewed the Indiantown Cogeneration, L.P. (Indiantown) Electric Power 

Plant Site Technical Evaluation and Preliminary Determination Document 

regarding a proposed cogeneration facility near Indiantown, Florida. The 

Indiantown facility will be a major source of nitrogen oxides (NO*), carbon 

monoxide, particulate matter, and sulfur dioxide (SOj), and will be located 

approximately 145 km north of Everglades NP, a class I air quality area 

administered by the National Park Service. We have the following comments 

regarding the Technical Evaluation and Preliminary Determination Document. 

We agree that the use of a baghouse to control particulate matter emissions, 

and a high efficiency (95 percent) spray dryer absorber to remove S02 

represents best available control technology for the proposed boiler. For NO, 

control, Indiantown proposes to use advanced combustion controls, low-NO* 

burners, and selective non-catalytic reduction (SNCR), resulting in a N0„ limit 

of 0.17 pounds per million Btu (lb/MMBtu). 

We understand that Indiantown's proposed N0X controls are the same as those 

proposed by Keystone Cogeneration Systems (Keystone) in Gloucester County, New 

Jersey. The Keystone permit allows an initial maximum NO* rate of 0.17 

lb/MMBtu, but also includes a condition that requires Keystone to design and 

optimize the SNCR system to achieve a NOx emission rate of less than 0.10 

lb/MMBtu. Another condition in the Keystone permit states that at the end of 

the first two-year operating period, the 0.17 lb/MMBtu limit shall be revised 

downward co reflect the rate that is demonstrated to be consistently achieved 

by the SNCR system. We recommend that if Indiantown does install the SNCR 

system, they be required to meet similar conditions as those in the Keystone 

permit. 

As you know, EPA-Region 4 recently revised the PSD permit for Orlando 

Utilities Stanton Unit 2. The permit now requires Orlando Utilities to 

install a Selective Catalytic Reduction (SCR) system on Unit 2 to reduce NOx 

emissions. The SCR system is to.be designed to achieve a NO, emission rate of 

less than 0.10 lb/MMBtu. Similarly, in December 1990, the New Jersey 
10/24/95 16:40 ©303 969 2822 WASO DENVER @003/017 

Department of "Environmental Protection granted a permit to Chambers 

Cogeneration that requires a SCR system designed to meet a 0.10 lb/MMBtu 

limit. ' Finally, the Virginia Department of Air Pollution Control recently 

issued draft permits for two coal-fired cogeneration facilities that require 

SCR to control N0X emissions (Hadson Power and Cogentrix-Dinwiddie). Given the 

recent developments in the SCR technology and the fact that other permitting 

authorities are now requiring SCR for coal-fired boilers, we ask that you 

require Indiantown to reconsider SCR for their proposed boiler as well. 

Indiantown used the EPA ISCST model for the cumulative class I increment 

analysis and included a total of 23 increment-consuming sources. The results 

of this analysis show that once in 1983 and once again in 1984 the 3-hour and 

24-hour class I S02 increments were exceeded (highest concentrations of 30.5 

micrograms per cubic meter (ug/m3) and 6.0 ug/m3, respectively). However, the 

high second-high concentrations during these episodes were below the allowable 

increment. Therefore, the class I increments for both the 3-hour and 24-hour 

averaging periods are exceeded, but not yet violated. The high second-high 

concentration for 1983 data was 4.8 ug/m3, which is 96 percent of the class I 

increment of 5 ug/m3. As you may know, if a proposed source will cause or 

contribute to a class I increment violation, the applicant will need to ask 

us to certify that there will be no adverse impacts to class I area resources 

before the project can be permitted. 

Indiantown only reported the high and high-second-high concentrations per year 

for our review. In the future, if the applicant is modeling with the ISCST 

model, we ask that they provide us with the "Max 50" table so that we can know 

more about the location and magnitude of impacts at other receptors in the 

park. In addition, Indiantown's total ambient analysis was overly 

conservative because they modeled all PSD and existing sources, and then added 

those concentrations to monitored ambient background levels. A more realistic 

total ambient impacts analysis for class I areas is performed by modeling the 

proposed source and any newly permitted, but not yet operating, source and 

adding these impacts to the ambient background concentrations. 

Indiantown performed a visibility analysis using the EPA model VISCREEN. The 

proposed project passed the Level I VISCREEN test, indicating that the 

proposed emissions would have low potential for visibility impairment due to 

plume impacts in Everglades NP. 

In our review of the Florida Power and Light Technical Evaluation and 

Preliminary Determination Document (May 1991) we identified our concerns with 

the effects, emissions from the proposed facility may have on the air quality 

related values (AQRVs) at Everglades NP. We also have the same general 

concerns vith the Indiantown project: The Indiantown Technical Evaluation and 

Preliminary Determination Document states that the predicted emissions from 

the proposed project, including a background''concentration, will be below the 

State's Ambient Air Quality Standards including the secondary National Ambient 

Air Quality Standards (NAAQS), which were designed to protect vegetation from 

the adverse impacts of air pollutants. The document states that this project 

is not expected to have a harmful impact on soils and vegetation. We wish to 

again clarify that there are documented effects below the NAAQS, and that 

compliance with the NAAQS does not ensure that there will be no negative 
P.5 

10/24/95 16:41 ©303 969 2822 WASO DENVER ©004/017 

impacts. The secondary NAAQS are based primarily on effects on cash crops and 

may not reflect a level of protection for all AQRVs such as native vegetation 

found in class I areas. In addition, the secondary NAAQS are national levels 

set to protect against effects due to multiple and diverse sources and may not 

provide adequate protection for sensitive species found in only one area of 

the country, nor do they address synergistic effects of multiple pollutants. 

Therefore, there may be instances, and ongoing studies are confirming this, 

where adverse effects to AQRVs can occur at levels below the NAAQS. 

The location of Everglades NP at the southern tip of the Florida peninsula 

allows for a unique ecosystem whose native communities reflect both temperate 

and subtropical influences. Studies have shown that fertilization can 

decrease the frost hardiness of certain plant species. We are concerned that 

the nitrates resulting from emissions would favor more frost tolerant species, 

thereby causing major shifts in community composition and structure. For 

example, South Florida slash pine (Pinus elliotti var. densa) is a major 

constituent of the upland park community, and is the predominant canopy tree 

species. The slash pines in the park grow on a limestone-derived soil, and 

they are most likely nitrogen limited. Fertilization by anthropogenic 

nitrogen could cause the pines to continue growing into the winter, increasing 

the likelihood of frost damage. Over time, the slash pines could be replaced 

by a tree species that is less responsive to fertilization. 

We are also concerned about the roles that nitrogen oxides and volatile 

organic compounds play as ozone precursors. Fumigation studies conducted in 

chambers have shown that slash pine seedlings are particularly sensitive to 

chronic ozone concentrations below the NAAQS. The seedlings showed reductions 

in root growth even before visible foliar injury was observed. We have not 

yet duplicated the experiment in the field to determine if current ozone 

levels in Everglades NP induce the same degree of growth reductions as were 

observed in the chambers. 

Lichens and bryophytes are common in the park, and due to their unique 

morphology, are particularly sensitive to air pollutants such as sulfur 

dioxide. The nitrates in acid rain may also be harmful to bryophytes, 

particularly to tank bryophytes which accumulate rainwater in a cup-shaped 

basin formed by overlapping leaves. Two species of epiphytes found in the 

park, Tillandsia flexuosa. a bromsliad, and Epidendrum noctumum. an orchid, 

are considered threatened under ths Preservation of Native Flora of Florida 

Act. The sensitivity of these two threatened species to air pollutants is not 

known at this time. 

Nitrogen oxide and sulfur dioxide emissions may lead to the acidification of 

the huge wetland system that comprises much of the park. Acidification leads 

to changes in the flora and fauna of an aquatic ecosystem. 

Finally, we are concerned about the high levels of mercury that have been j 

found in the federally endangered Florida panther and other animals in the / 

park. It is not known at this time what the source of the mercury is, but we I pOi 

encourage you to limit mercury emissions in the vicinity of the park until the \ w ' 

source can be identified and remedial action taken. -.— 

H< 
P.6 

10/24/95 16:41 ©30 3 969 2822 WASO DENVER 0005/017 

If you have any"questions regarding this matter, please contact Dee Morse of 

our Air Quality Division in Denver at (303) 969-2071. 

Sincerely, 

Regional Director 

Southeast Region 

bcc: 

SERO: AQC 

EVER: Supt. 

AQD-DEN: Morse 
PJ_ 

10/24/95 16:41 ©303 969 2822 WASO DENVER 1^1006/017 

Review of Technical Evaluation and 

Preliminary Determination Document for 

Florida Power and Light Company's 

Martin Coal Gasification/Combined Cycle Project 

by 

Policy, Planning, and Permit Review Branch 

Air Quality Division, National Park Service 

INTRODUCTION 

Florida Power and Light Company (FPL) is proposing a generation expansion 

project at its Martin Power Plant site in Martin County, Florida. The 

expansion project is called the Martin Coal Gasification/Combined Cycle 

(CG/CC) project, and consists of four, 400 MW CGlCC units. Each combined 

cycle unit will consist of two combustion turbines and two heat recovery steam 

generators. The Martin facility is located 13 km northwest of Indiantown, and 

141 km north of Everglades National Park (NP), a class I air quality area 

administered by the National Park Service. 

The Martin CG/CC project will be built in three phases. Phase I will consist 

of the addition of two new combined -cycle units (Units 3 and 4), to be fired 

primarily by natural gas, with No. 2 distillate fuel oil as a backup fuel. 

Phase II will consist of the addition of the other two combined cycle units 

(Units 5 and 6). In Phase III, coal gasification facilities will be added, 

which will include four units to serve as the source of fuel for the four 

combined cycle units installed in Phases I and II. 

The proposed project also consists of two auxiliary steam boilers (60,000 

lb/hr each) for start-up and two, 750 KW diesel generators for emergency 

electricity. In addition, at the site there are two existing 863 MW No. 6 

fuel oil/natural gas fired boilers. 

The significant emission increases that would result from the Martin CG/CC 

project are estimated as follows: 

Pollutant 

Sulfur Dioxide (S02) 

Nitrogen Oxides (N0X) 

Carbon Monoxide (CO) 

Sulfuric Acid Mist (H2S0,) 

Particulate Matter (PM) 

PMl0 

Volatile Organic Compounds 

Lead (Pb) 

Mercury (Hg) 

Inorganic Arsenic (As) 

Beryllium (Be) 

Emissions Increase 

(tons/year) 

30,065 

15,172 

4,785 

3,677 

2,264 

2,264 

(VOC) 774 

11.5 

0.98 

0.62 

0.02 
PJ3_ 

10/24/95 16:42 ©303 969 2822 WASO DENVER ifl007/01/ 

Following are our comments on the best available control technology analysis, 

the air quality analysis, and the proposed project's potential impacts on the 

air quality related values at Everglades NP. 

BEST AVAILABLE CONTROL TECHNOLOGY (BACT) ANALYSIS 

To minimize emissions of all the pollutants listed above (except NO,) from the 

proposed turbines, FPL proposes to utilize proper combustion techniques and 

to fire the turbines with clean fuels (initially, natural gas and low sulfur 

oil). We agree that these measures constitute BACT for these pollutants. 

However, we do not agree that the proposed 0.5 percent maximum sulfur content 

No. 2 fuel oil (average of 0.3 percent sulfur) is the "best" fuel oil that is 

available. In addition, we do not agree with the statement in the Florida 

Department of Environmental Regulation's (FDER) BACT discussion that this 

sulfur content is consistent with what has been established as BACT on a 

national basis and for recent permitting of gas turbines in Florida. Just 

recently, the FDER determined that BACT for a combustion turbine proposed by 

the City of Lakeland is burning a fuel oil with a maximum sulfur content of 

0.20 percent. Also, we have reviewed other combustion turbine projects that 

were permitted to burn No. 2 fuel oil with a maximum sulfur content of 0.20 

percent. In fact, New Jersey has recently issued combustion turbine permits 

that specified kerosene with a maximum sulfur content of 0.04 percent as the 

turbine backup fuel. Because the proposed FPL turbines would be permitted to 

fire fuel oil only up to 500 hours per year per turbine, the added costs 

associated with burning a lower sulfur content oil should not be prohibitive. 

Therefore, given the potential S02 class I increment problems discussed below 

(see Air Quality Analysis section), the potential impacts on sensitive air 

quality related resources at the park (see Air Quality Related Values Analysis 

section), and the fact that lower sulfur content oils are being required for 

other gas turbine projects, we recommend that the FDER lower the maximum 

sulfur content for the FPL turbines from 0.5 percent to 0.20 percent. 

For control of N0X emissions, FPL proposes to use a dry low N0X combustor 

turbine design. The resulting N0X rate proposed for the turbines is 25 parts 

per million (ppm) for gas firing, 42 ppm for coal derived gas firing, and 65 

ppm for oil firing. Florida Power and Light and the FDER also considered 

Selective Catalytic Reduction (SCR) as an alternative N0X control system. For 

natural gas firing, the SCR technology could reduce NO. emissions from the 

proposed turbines to less than 9 ppm, but at a substantial cost. The FDER 

calculated a cost effectiveness of $7,590 per ton of N0X removed to reduce the 

turbine N0X emissions from the proposed 25 ppm level to 9 ppm. Based on this 

cost effectiveness value, the FDER determined that the use of SCR technology 

is not justified at this time. However, for coal derived gas firing, which 

is proposed for Phase III, the cost effectiveness of using SCR to reduce N0X 

emission? from 42 ppm to 9 ppm is only S3,506 per ton, which appears 

reasonable. Consequently, we are pleased that the FDER will require an indepth cost analysis for SCR when FPL elects to proceed with the permitting for 

Phase III of the project. 
10/24/95 16:42 ©303 969 2822 WASU UtAvtK ; _~Z~77ZT, 

If the proposed "low N0X combustor" design, rather than a "standard" combustor 

design (42 ppm N0X for gas firing), is used as the base case in the BACT 

determination, we agree that SCR technology is not cost effective on a dollars 

per ton basis. We also agree that with the 500 hours per year per turbine 

fuel oil limitation, SCR is not cost effective for the FPL turbines. However, 

although SCR will not be required at this time, we also believe that this 

technology should be given serious consideration for the coal derived gas 

option, and for future permit applications for combined-cycle gas turbine 

projects as well. 

It is interesting to note that if the cost effectiveness calculation for SCR 

is made assuming a standard combustor turbine design, the use of SCR could be 

considered reasonable. For example, as mentioned above, using the SCR costs 

provided by FPL, the cost effectiveness to reduce N0„ emissions from 42 ppm to 

9 ppm with SCR would only be $3,506/ton. In essence, by choosing an 

"intermediate" N0X control strategy, and using this strategy as the base case, 

FPL is not being required to use SCR when firing natural gas. However, it is 

also evident that the BACT process is driving emissions downward, and that 

applicants are looking for ways to inherently lower emissions, rather than 

opting for add-on flue gas cleaning technologies. Assuming this process 

continues, and inherently lower emitting systems are developed, such an 

approach may be preferred from a total environmental standpoint. 

AIR QUALITY ANALYSIS 

Florida Power and Light used EPA's Industrial Source Complex Short Term 

(ISCST) model to predict air quality impacts of the proposed project. The 

analysis examined five years of West Palm Beach, Florida, National Weather 

Service (NWS) data from 1982-1986. Florida Power and Light only modeled out 

to a distance of 50 km from the Martin facility. Consequently, they did not 

address air quality impacts at Everglades NP (141 km away). The results of 

FPL's analysis show that the proposed emissions would not cause or contribute 

to violations of the class II PSD increments or the National Ambient Air 

Quality Standards. However, because impacts were not predicted for Everglades 

NP, we do not know if the proposed emissions, in combination with all other 

increment-consuming sources, would cause class I increment exceedances at the 

park. We also do not know what the total ambient pollutant concentrations 

would be at the park. 

On page 54 of the FDER's Technical Evaluation and Preliminary Determination 

Document, it states: 

"Although the proposed source has a significant impact for S0Z at 

a distance greater than 50 km from its site, the model is limited 

to use within a 50 km distance for regulatory applications. 

However, given the predicted impacts at 50 km for each of these 

pollutants, and the long distance' to the Everglades, it is 

unlikely that the proposed source would -significantly impact the 

Class I Area." -• 
P.10 

10/24/95 16:43 ©303 969 2822 WASO DENVER ©009/017 

We disagree with both of these statements.•..•; First, for regulatory applications 

with potential impacts on a class I area, use of the ISCST model is not 

necessarily liiffited to 50 km. Using a 50 km cutoff for modeling class I 

impacts would be inconsistent with EPA's modeling guidelines. 

While it is true that EPA has provided guidance on the use of dispersion 

models and generally limits the application of air quality models to a 

downwind distance of no more than 50 km, it should be noted that an exception 

was made to these guidelines for cases when a class I area might be impacted. 

Referring to the 50 km limitation EPA states, "... since the 1977 Amendments 

provide special concern for class I areas, any reasonably expected impacts for 

these areas must be considered irrespective of the 50 kilometer limitation or 

the above significance levels." (See June 19, 1978, Federal Register, p. 

26398). 

In addition, Section 7.2.6 of-EPA'S-"Guideline on Air Quality Models", revised 

July 1986, states in part: -

"Section 165(e) of the Clean Air Act requires that suspected 

significant impacts on PSD Class I areas be determined. However, 

the useful distance to which most Gaussian models are considered 

accurate for setting emission limits is 50 km. Since in many 

cases Class I areas may be threatened at distances greater than 

50 km from new sources, some procedure is needed to (1) determine 

if a significant impact will occur, and (2) identify the model to 

be used in setting an emission limit if the Class I increments are 

threatened (models for this purpose should be approved for use on 

a case-by-case basis as required in Section 3.2). This procedure 

and the models selected for use should be determined in 

consultation with the EPA Regional Office and the appropriate 

Federal Land Manager (FLM).P 

Second, we do not agree with the statement that it is unlikely that the 

proposed emissions would significantly impact Everglades NP. In order to 

assess the class I S02 and N02 increment consumption at Everglades NP as a 

result of the proposed FPL emissions, we performed a dispersion modeling 

analysis using the ISCST model and 1986 West Palm Beach, Florida, surface and 

upper air NWS meteorological data. For our short-term analyses (3-hr, 24-hr 

averaging times), we modeled the proposed emissions from the eight turbines 

assuming fuel oil firing (0.5 percent sulfur content). The tail gas 

incinerators associated with Phase III, the emergency backup diesel 

generators, and the start-up steam boilers were not modeled. This source 

configuration provides a realistic evaluation of actual conditions since the 

emergency _generator and start up boilers will not normally operate 

simultaneously with the gas turbines, and the turbines will not fire oil when 

the coal derived gas is being produced (i.e., when the tail gas incinerators 

are in operation). 
_ — _ P.11 

10/24/95 16:44 ©303 969 2822 WASO DENVER ©010/017 

The emissions used in this analysis were those found in Table 3, "Maximum 

Pollutant Emissions for the Proposed Project", on page 51 of the FDER's air 

quality analysis. The stack parameters applied were those also provided by 

the FDER (Table 2, page 50). The ISCST model was run using polar coordinates 

and receptors at the northern boundaries of Everglades NP. The directions and 

distances from the Martin facility used in the analysis are as follows: 170 

degrees - 205 km; 180 degrees - 141 km; 190 degrees - 164 km; 200 degrees -

152 km; 210 degrees - 157 km. Based on the results of our analysis, using the 

one year of 1986 meteorological data, a total of 76 days at these 5 receptors 

will experience a 24-hour concentration of greater than 1 ug/m3, which is the 

level that is often incorrectly cited as the class I significant impact level. 

The highest concentration modeled was 3.06 ug/m3 at 200 degrees - 152 km, on 

day 235. The maximum class I 3-hour and annual S02 concentrations predicted 

were 16.47 ug/m3 and 0.14 ug/m3, respectively. The annual N02 Class I increment 

impact was 0.082 ug/m3. The S02 3-hr and 24-hr predicted concentrations are 

66 percent and 61 percent of the total allowable class I increments, 

respectively. Modeling of only the four turbines proposed for Phase I 

indicates 3-hour and 24-hour average impacts of 8.25 ug/m3 and 1.53 ug/m3, 

which are still 33 percent and 31 percent of the allowable class I increments, 

respectively. 

We realize that use of the ISCST model at a distance of 141 km may be 

stretching the validity of this model. However, use of this model to 

calculate a 24-hour average concentration -may be considered conservative 

because of plume integrity at this distance. Plume integrity for 3 hours 

cannot be considered an issue. Review of the highest 24-hour period (day 235 

at 200 degrees) indicates that for 5 hours, the atmospheric stability and wind 

speed were nighttime E and F stability and 2 to 4.6 m/sec wind speed. Stable 

conditions with moderate wind speeds are conducive to a plume remaining intact 

over flat terrain, and therefore, long range transport is probable. If they 

so choose, FPL can address long range impacts for Phase I of the project, as 

well as for Phases II and III, with the EPA Appendix "B" model MESOPUFF II. 

We are available to discuss the use of this model. 

It is important to note that our analysis only included emissions from the 

proposed FPL turbines. No other increment-consuming sources were included in 

our analysis. If such sources were modeled, it is possible that the proposed 

emissions could cause or contribute to class I increment exceedances 

(especially for the S02. 3-hr and 24-hr averaging times) at Everglades NP. 

As mentioned above, our short-term analyses included S02 emissions based on 

firing the proposed 0.5 percent maximum sulfur content fuel oil. Because the 

predicted S02 concentrations are directly proportional to the S02 emissions, 

which are, in turn, directly proportional to the sulfur content of the fuel, 

the predicted ambient concentrations could be lowered by lowering the sulfur 

conter.t of the oil. For example, if the maximum sulfur content of the backup 

fuel oil was lowered from 0.5 percent to 0.20 percent, as recommended above 

(see BACT section), the estimated S02 emissions would be reduced by 60 percent, 

resulting in a 60 percent reduction in predicted S02 concentrations at 

Everglades NP. 

><.u* 
10/24/95 16:44 ©303 969 2822 WASO DENVER 

If such reductions occurred, we would feel mote confident tha 

P.12 

0011/017 

t the -Drcraased 

emissions would not cause increment exceedances at the park. However, because 

the increment status at Everglades NP would still be uncertain even under the 

lower emissions scenario, we recommend that the FDER include a condition in 

the FPL permit that makes it clear that class I impacts must be adequately 

assessed before construction of Phases II and III may commence. 

In addition to not predicting increment impacts at Everglades NP, FPL also 

failed to estimate the total ambient concentration levels at the park. To 

assess potential impacts on sensitive air quality related values, it is 

important for us to know the total ambient concentrations (increment plus 

background) at the class I area. A cumulative analysis should include all 

permitted and existing sources within 50 km of the facility's impact area that 

could potentially impact the class I area (this is especially important for 

annual effect determinations). 

In conclusion, we have determined that the FPL air quality analysis is 

deficient because it does not address class I increment or total ambient 

impacts at Everglades NP. Unless FPL is willing to lower the maximum sulfur 

content of the fuel oil to 0.20 percent, they should model their emissions, 

plus all other increment consuming emissions, to determine whether the 

emissions from the proposed Martin CG/CC project would cause or contribute to 

class I increment exceedances at Everglades NP. Such an analysis should use 

all five years of meteorological data. The incremental impacts, when added 

to the impacts from all other background sources of S02, N02, and ozone should 

then be used to evaluate the effects on the sensitive air quality related 

values in Everglades NP (see Air Quality Related Values Analysis below). 

AIR QUALITY RELATED VALUES (AQRVs) ANALYSIS 

Terrestrial and Aquatic Effects 

The FDER's Technical Evaluation and Preliminary Determination Document (page 

56) states that since the proposed project would not cause any exceedances of 

the secondary National Ambient Air Quality Standards (NAAQS), which were 

designed to protect vegetation from the adverse Impacts of air pollutants, 

there would not be any effect on vegetation. We wish to clarify that there 

are documented effects below the NAAQS, and that compliance with the NAAQS 

does not ensure that there will be no negative impacts. The secondary NAAQS 

are based primarily on effects on cash crops, such as wheat and tobacco, and 

may not reflect a level of protection for all AQRVs such as native vegetation 

found in class I areas. In addition, the secondary NAAQS are national levels 

set to protect against effects due to multiple and diverse sources and may not 

provide adequate protection for sensitive. species found in only one area of 

the country, nor do they address synergistic effects of multiple pollutants. 

Therefore, there may be instances, and ongoing studies are confirming this, 

where adverse effects to AQRVs can occur at levels below the NAAQS. 
P.13 

10/24/95 16:45 ©303 969 2822 WASO DENVER 1^1012/017 

The location of Everglades NP at the southern tip of the Florida peninsula 

allows for a unique ecosystem whose native communities reflect both temperate 

and subtropical-influences. Much of south Florida's vegetation is shaped by 

two competing forces: 1) recurring winter freezes that limit the northward 

expansion of subtropical species, and 2) in mild year3, the lack of cold 

weather that many temperate species require to break dormancy. Studies have 

shown that fertilization can decrease the frost hardiness of certain plant 

species. We are concerned that the nitrates resulting from emissions would 

favor more frost tolerant species, thereby causing major shifts in community 

composition and structure. For example, South Florida slash pine (Pinus 

elliotti var. densa) is a major constituent of the upland park community, and 

is the predominant canopy tree species. The slash pines in the park grow on 

a limestone-derived soil, and they are most likely nitrogen limited. 

Fertilization by anthropogenic nitrogen could cause the pines to continue 

growing into the winter, increasing the likelihood of frost damage. Over 

time, the slash pines could be replaced by a tree species that is less 

responsive to fertilization. 

We are also concerned about the roles that N0X and VOC emissions play as ozone 

precursors. Fumigation studies conducted in chambers have shown that slash 

pine seedlings are particularly sensitive to ozone injury. The seedlings 

showed reductions in root growth even before visible foliar injury was 

observed. We have not yet duplicated the experiment in the field to determine 

if current ozone levels in Everglades NP induce the same degree of growth 

reductions as were observed in the chambers. 

Lichens and bryophytes %re common in the park, and due to their unique 

morphology, are particularly sensitive to air pollutants such as S02. The 

nitrates in acid rain may also be harmful to bryophytes, particularly to tank 

bryophytes which accumulate rainwater in a cup-shaped basin formed by 

overlapping leaves. Two species of epiphytes found in the park, Tillandsia 

flexuosa. a bromeliad, and Epidendrum nocturnum. an orchid, are considered 

threatened under the Preservation of Native Flora of Florida Act. The 

sensitivity of these two threatened species to air pollutants is not known at 

this time. 

Nitrogen oxide and S02 emissions may lead to the acidification of the huge 

wetland system that comprises much of the park. Acidification leads to 

changes in the flora and fauna of an aquatic ecosystem. The abundance and 

biomass of benthic invertebrates decreases and the community composition 

changes as the pH of the water drops. The loss of prey can result in a 

decline in fish populations. Additionally, many amphibian and fish species 

are unable to reproduce at low pH levels. This has a profound effect on 

consumers higher up the food chain. The federally endangered Everglade kite, 

peregrine falcon, southern bald eagle, brown pelican, and American crocodile 

found in Everglades NP all depend, to a lesser or greater extent, on an 

abundant supply of fish and amphibians for food. 
10/24/95 16:45 ©303 969 2822 WASO DENVER mJl'l*. 

W\ 

Finally, we are concerned about the high levels of mercury that have beenl 

found in the federally endangered Florida panther and other animals in the 1 

park. It'is not known at this time what the source of the mercury ia, but we \ 

encourage the FDER to limit mercury emissions in the vicinity of the park \ j 

[ until the source can be identified and remedial action taken. ^J 

Visibility Impacts 

Florida Power and Light did perform a visibility analysis using the VISCREEN 

model for a Level 1 screening analysis. Based on this analysis, the FDER 

concluded that no Impact on visibility is expected at Everglades NP as a 

result of the proposed facility. However, the FDER did not include any of the 

data used in the analysis, such as background ozone concentrations or visual 

range• 

As we have indicated in past reviews, the broad conclusion that no visibility 

impacts are expected based on a VISCREEN analysis cannot be justified based 

on the type of model that was used. VISCREEN is a plume visual impact 

screening model intended for use in evaluating the potential for visibility 

impairment due to plume impacts. In this case, the modeling results only 

allow a conclusion that there is low potential for visibility impairment due 

to plumes in the class I area as a result of emissions from the proposed 

project. VISCREEN cannot determine a source's potential to contribute to 

regional haze, which is the most insidious visibility problem in Everglades 

NP and the surrounding region. Visibility in the southern and eastern U.S. 

has degraded steadily since the early 1950's, with the most dramatic changes 

occurring in the summer months. On an annual average basis, sulfates are 

responsible for nearly 40 percent of the mass budget and over 50 percent of 

the light extinction budget in the park; nitrates contribute about 15 percent 

to light extinction; and organics account for between 15 percent to 25 percent 

of the light extinction, depending on assumptions about the hygroscopic 

characteristics of these compounds. There is some seasonal variability of 

visibility-reducing aerosols, but sulfates predominate as the most Important 

contributor to visibility reduction in every season, with contributions 

ranging from 42 percent in the summer to as high as 64 percent in the spring. 

Nitrates and organics continue to be next in importance. Monitoring and 

recently developed models may provide a means of assessing the contribution 

of individual sources to this problem. 

We encourage the FDER to take all steps possible to reach national and State 

visibility goals by limiting pollutants, such as S02, N0X. and PM, that 

contribute to visibility degradation not only in Everglades NP, but in the 

whole region. 

CONCLUSIONS AND RECOMMENDATIONS 

1. Given the potential S02 class I increment problems and the potential 

impacts on sensitive air quality related resources at Everglades NP, and 

the fact that lower sulfur content oils are being required for other gas 

turbine projects, we recommend that?• the- FDER lower the maximum sulfur 

content for the FPL turbines-from 05spercent to 0.20 percent. 

8 
P.15 

10/24/95 16:46 ©303 969 2822 WASO DENVER Ifl014/017 

2. We recommend that the FDER seriously consider Selective Catalytic 

Reduction to control turbine N0X emissions for the coal derived gas 

option, and for future permit applications for combined-cycle gas turbine 

projects as well. 

3. Considering the potential class I increment violations and impacts to 

visibility and other air quality related values at Everglades NP, if the 

FDER does not lower the FPL fuel oil limitation to 0.20 percent, FPL 

should perform cumulative increment and ambient impact analyses for 

Everglades NP. 

4. The FDER should include a permit condition in the FPL permit that makes 

it clear that class I impacts must be adequately assessed before 

construction of Phases II and III may commence. 

5. The State of Florida should take all steps possible to reach national and 

State visibility goals by limiting pollutants, such as S0Z, N0J( and PM, 

that contribute to visibility degradation not only in Everglades NP, but 

in the whole region. 

6. In order for us to be able to adequately assess potential impacts on 

sensitive air quality related values, future class I impact analyses 

should include estimates of the total ambient concentrations (increment 

plus background) at the class I area. 

":>U 
10/24/9 5 16:46 ©30 3 969 2822 WASO DENVER ifijoia/l?.* 

b 

N3615 (SER-ODN) 

Mr. Clair Fancy 

Chief, Bureau of Air Regulation 

Florida Department of Environmental Protection 

Twin Towers Office Building 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Mr. Fancy: 

We have reviewed the revised draft Prevention of Significant Deterioration 

permit modification request for the Dade County Resource Recovery Facility 

(Dade County) located in Miami, Florida. Dade County is located approximately 

10-km east of Everglades National Park (NP), a Class I air quality area 

administered by the National Park Service. 

Dade County is proposing to upgrade the air pollution control equipment on 

four municipal waste combustors resulting in reductions of particulate matter, 

acid gases and mercury emissions. The emissions from each combustor unit 

would be controlled by a spray dryer scrubber followed by a baghouse and a 

mercury co.ftti.ol tjybitfflT we agree that thesS eontrals represent the best 

available control technology. 

Based on our review of the permit application and given the associated 

emission decreases, the proposed project should have a net air quality benefit 

on sensitive resources at Everglades NP. 

We appreciate receiving this application early in the review process. Please 

provide us a copy of the final permit upon completion. In the meantime, if 

you have any questions regarding our comments, please contact Bud Rolofson of 

our Air Quality Division in Denver at (303) 969-2071. 

Sincerely, 

Regional Director 

Southeast Region 

bcc: 

SER0: AQC (Brendhan Zubricki) 

EVER: Supt 

AQD-DEN: Bud Rolofson 
P.17 

10/24/95 16:47 ©30 3 969 2822 tfASO DENVER 10016/017 

Mr. C. H. Fancy 

Chief, Bureau of Air Regulation 

Florida Department of Environmental Regulation 

Twin Towers Office Building 

2600 Blair Stone Road 

Tallahassee, Florida 32399-2400 

Dear Mr. Fancy: 

We have reviewed the Prevention of Significant Deterioration (PSD) 

Application for the new cement kiln (kiln #2) proposed by Florida Crushed 

Stone (FCS) Company. The kiln would be located 20 km southeast of 

Chassahowitzka Wilderness Area (WA), a Class I air quality area 

administered by the U.S. Fish and Wildlife Service (FWS). The new kiln 

would emit significant amounts of PM-10, sulfur dioxide (S0:), nitrogen 

oxides (NO.), and carbon monoxide. FCS currently operates kiln lfl at the 

site. 

We understand that another PSD application has been submitted for a 

modification to the power plant on the FCS property. This application was 

submitted by Central Power and Lime, formerly Florida Crushed Stone. Both 

Central Power and Lime and Florida Crushed Stone are under common 

ownership/control, and therefore emissions from both proposed projects 

should be considered together for PSD review. 

Air Quality Analysis 

The air quality impact analysis for the proposed cement kiln is incomplete. 

The information in the permit application and the additional modeling 

analysis (March 21, 1995) is insufficient to determine whether emissions 

from the proposed new kiln (kiln #2) and other sources at the facility 

(kiln #1 and the power plant) would have a significant impact at 

Chassahowitzka WA. We understand that your office will be requiring 

additional modeling to be performed before the application is deemed 

complete. We request that FCS model Class I area impacts using revised 

facility emission rates specified by your office. Upon review of the 

revised modeling analysis, we will determine if a cumulative S02 Class I 

increment analysis is required. Also, if there is a change in the 

facility's'NO, or PM-10 emission rates from the present analysis, those 

Class I impacts must also be recalculated. The March 21, 1995, analysis 

indicated that a cumulative nitrogen dioxide (N02) Class I increment 

analysis is required because predicted N02 impacts exceed the FWS Class I 

significant level of 0.025 micrograms per cubic meter. 

r

The revised air quality impact analysis should* also include annual impacts 

from lead (Pb), beryllium (Be)s, and mercury (Hg) emissions to the Class I 

area. The effects on resources from these pollutants should be addressed 

in the air quality related values analysis. 
10/24/95 16:47 ©303 969 2822 WASO DENVhK

 BJ3

-

The VISCREEN analysis was incorrectly done. The emissions of sulfuric acid 

mist (H2S0<) from the proposed kiln should be included in the analysis as 

primary sulfate (SOJ . Also, the VISCREEN 2 analysis applied wind speed 

changes to the meteorological data that are inappropriate. The 

Environmental Protection Agency document on VISCREEN (Workbook for Plume 

Visual Impact Screening and Analysis. EPA-450/4-88-015, September 1988) 

does not indicate that compensation to wind speeds, using wind speed 

profile adjustments calculations, are to be applied. The revised VISCREEN 

analysis should not apply these wind speed profile changes. In addition, 

the analysis assumed a background visual range (BVR) of 25 km. The 

analysis should be done using a BVR of 65 km, the 90th percentile annual 

visual range for the wilderness area. 

Due to the complex nature of this permit application, please require the 

applicant to submit, in addition to the written analysis, the modeling 

input and output files to us on a 3.5 floppy disk(s) for both the increment 

and visibility modeling analyses. 

Best Available Control Technology (BACT) 

The BACT analysis appears to be complete. 

Air Quality Related Values (AQRV) Analysis 

No Class I AQRV analysis was done, and thus, this part of the application 

is incomplete. 

Thank you for giving us the opportunity to comment on this permit 

application. We appreciate your cooperation-in notifying us of proposed 

projects with the potential to impact the air's quality and related resources 

of our Class I air quality areas. If you have questions, please contact 

Ellen Porter of our Air Quality Branch in Denver at (303) 969-2617. 

Sincerely, 

Noreen K. Clough 

Regional Director 

cc: Jewell Harper, Chief ' 

Air Enforcement Branch 

Air, Pesticides and Toxic Management Division 

"J.S. EPA, Region 4 --

345 Courtland Street, NE ••;•:•.: <-...-!xMi. 

' Atlanta, Georgia 30365' -^ •• 

bcc: FWS-REG. 4: AQC 

CHAS: Refuge Manager 

AQD-DEN: Ellen Porter 

National Park Service - AIR 

P.O. Box 25287 

Denver, CO 80225